Angichiodo v. Honeywell Pension and Savings Plan, 2:15-cv-00097

Background

Plaintiff is the surviving spouse of a vested participant in Honeywell’s defined-benefit Plan; the participant had elected a pre-retirement option providing a 50% survivor benefit.
The participant became terminally ill but did not complete retirement paperwork before his death; Plaintiff alleges neither she nor her husband contacted the Honeywell Retirement Service Center until after his death.
After his death, Plaintiff spoke to a call-center representative who incorrectly suggested a supervisor/HR could initiate retirement for a terminally ill employee; Plaintiff later learned no procedure existed to expedite retirement or waive the Plan’s minimum 45-day verification period.
Plaintiff sued under ERISA asserting failure to pay benefits (later resolved administratively) and equitable fiduciary-duty claims based on alleged concealment of a terminal-illness retirement process and inadequate training/misrepresentations.
The Court granted summary judgment for Defendants on the fiduciary-duty/equitable claims (no duty to disclose a procedure that did not exist) and later considered Defendants’ motion for attorneys’ fees and non-taxable costs.
Defendants sought $533,217.46; the Court applied the Hummell factors, found plaintiff’s suit was groundless, considered plaintiff’s limited ability to pay, and awarded a reduced fee of $25,000 plus interest.

Issues

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Defendants are entitled to attorneys' fees under 29 U.S.C. § 1132(g)(1)	Angichiodo argued her equitable fiduciary claims sought relief for nondisclosure of a retirement-expedited procedure and thus were enforceable	Defendants argued plaintiff achieved only limited success, her claims were groundless (based on a non-existent procedure), and fees are justified to deter meritless ERISA suits	Court: Defendants met "some degree of success" threshold; after Hummell analysis, awarded reasonable fees ($25,000) rather than the full amount requested
Whether plaintiff reasonably believed she could prove an actionable ERISA claim (bad faith/culpability)	Plaintiff contended she relied on statements and alleged misrepresentations and pursued equitable relief	Defendants contended plaintiff’s claim rested on a false assumption about a procedure that did not exist and the administrative record corrected the misunderstanding before suit	Court: Plaintiff’s belief was unreasonable; this Hummell factor favors fee award
Whether fee award would deter others or chill meritorious ERISA claims	Plaintiff argued a fee award would chill ERISA enforcement	Defendants argued deterrence of groundless litigation is appropriate; plaintiff did not seek benefits under plan terms but equitable relief based on a non-existent practice	Court: Fee award would deter groundless suits and is warranted, but should not unduly chill meritorious claims; favors a reduced award
Whether plaintiff can pay the requested fees	Plaintiff provided financial declaration showing limited assets and income and existing debts	Defendants argued full fees are appropriate despite plaintiff’s finances	Court: Plaintiff’s limited ability to pay counseled against awarding the full amount; factor weighed against full recovery of requested fees

Key Cases Cited

Hardt v. Reliance Standard Life Ins. Co., 560 U.S. 242 (establishes “some degree of success on the merits” threshold for fee awards under § 1132(g)(1))
Simonia v. Glendale Nissan/Infinity Disability Plan, 608 F.3d 1118 (discusses application of Hummell factors in ERISA fee awards)
Hummell v. S.E. Rykoff & Co., 634 F.2d 446 (sets five-factor test for ERISA fee awards)
Cline v. Indus. Maintenance Eng’g & Contracting Co., 200 F.3d 1223 (reasonableness of plaintiff’s belief bears on bad-faith/culpability Hummell factor)
Estate of Shockley v. Alyeska Pipeline Serv. Co., 130 F.3d 403 (discusses punitive/deterrent considerations in awarding ERISA fees)